G.R. No. 137451. July 28, 2005
JOSE RUBIATO, Petitioner, vs. THE HEIRS OF JOVITO RUBIATO, Respondents.

FACTS

The property in dispute is Farm Lot No. 639 in Koronadal, South Cotabato, originally allocated by the NARRA to spouses Anastacio and Catalina Dignadice. Catalina sold the lot to petitioner Jose Rubiato in 1950. In 1991, Jose filed a complaint against the heirs of his deceased brother, Jovito Rubiato, for recovery of possession and ownership. He alleged that Jovito procured title to the lot through fraud and forgery, specifically by submitting a forged 1955 letter wherein Jose purportedly resigned his settler’s rights in Jovito’s favor.
Respondents denied the allegations, asserting that Jose voluntarily transferred possession and cultivation to Jovito and was aware long before Jovito’s death that the lot had been titled in Jovito’s name. The Regional Trial Court dismissed Jose’s complaint, finding that the lot was still public land in 1955, and Jose had never applied for its titling, thus acquiring no vested right. The court also ruled that Jose slept on his rights for over 36 years.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of Jose Rubiato’s complaint for recovery of possession and ownership.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The core issues raised by petitioner—involving the validity of the document transferring rights and the applicability of laches—are intrinsically factual, requiring a re-evaluation of evidence. The Court reiterated the fundamental doctrine that it is not a trier of facts. Factual findings of the trial court, especially when affirmed by the Court of Appeals, are binding and conclusive if supported by substantial evidence.
In this case, both lower courts uniformly found that at the critical time of the alleged forgery in 1955, the farm lot remained public land. Jose Rubiato never applied for a homestead patent or took steps to perfect his claim, thereby failing to acquire any vested equitable right over the property that could be violated. Consequently, the validity of the contested letter became immaterial to Jovito’s subsequent lawful acquisition of title. Moreover, the courts found that Jose had knowledge of his brother’s application and the issuance of title as early as 1954 but took no action until 1991, constituting laches. The Supreme Court found no compelling reason to deviate from these factual conclusions, as no essential facts were overlooked that would alter the outcome.